Document and implement policies and procedures to ensure that data observations for key assumptions that are inconsistent with FHA’s understanding of program operations are researched and further analyzed and that all results are concurrently documented and included in the model documentation.

Update the posting models to ensure that refunds relating to payments made in prior years are properly recorded in accordance with OMB Circular A-11.

Correct the programming error in the HERMIT system to ensure that the correct insurance-in-force balances are reported on the note disclosures.

Develop policies and procedures to ensure that the line items in the required note disclosures are understood, properly calculated, and properly disclosed in the financial statements in accordance with OMB Circular A-136.

Work with the City of Denver Office of Economic Development to recapture $37,000 in HOME funds not properly used for the affordable housing projects.

Require Del Norte to develop policies and procedures to prevent ineligible affordability period transfers.

Develop and implement adequate enforcement procedures that support its policy and ensure that housing quality standards deficiencies are corrected in a timely manner.

Implement a process to periodically audit or reconcile ARC’s records.

Implement a process to periodically review approving officials’ span of control to ensure that the requirement is not exceeded.

Implement a process with ARC to ensure that cardholders and approving officials are notified before purchase card training is due to allow training to be completed in a timely manner.

Implement a process to ensure that purchase cards are suspended when a cardholder or approving official fails to complete training.

Research why ARC provided incomplete monthly transactional data and identify a solution to ensure the completeness of future transmissions.

Enhance the process to periodically analyze data for split transactions or improper MCCs and follow up on any potential issues identified.

Require ARC to update its MCC tracking log, to include the amount, the date of MCC override removal, and staff assigned, to ensure that an override is removed after the approved purchase is made.

Implement a process with Citibank and ARC to provide global notifications to cardholders and approving officials before autoclosures of credit card statements.

Implement a process to suspend cardholders or approving officials who repeatedly cause HUD to pay interest.

Obtain supporting documentation for the $1,807 spent on two cardholders’ purchase cards or require the vendors or cardholders to repay the funds to the applicable HUD program.

Suspend the travel cards for 35 employees who made 166 improper, illegal, or erroneous purchases, if warranted based on the nature of misuse, and coordinate with the related program offices, the Office of the Chief Human Capital Officer, and the Office of Employee Labor Relations to take appropriate disciplinary actions against these employees and their supervisors who did not follow up on the monitoring reports.

Ensure that ARC has properly updated the monitoring report criteria to include transaction categories that were previously missing from the monitoring reports.

Coordinate with the Office of Employee Labor Relations and the Office of the Chief Human Capital Officer to update HUD’s travel card policy with the table of penalties and disciplinary actions for travel card misuse and provide the updated policy and tiered instructions for disciplinary actions to administrative officers and approving officials.